1.0 Introduction
This statement has been published in accordance with Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015. It sets out the steps taken by FootfallCam (FFC) and its group of companies' activities for the financial year ending 2021 to prevent modern slavery and human trafficking in its business and supply chains.
FFC has taken steps to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This statement is only in relation to FFC and its business, not the business of its member firms (as further explained below). References to "our people" only refers to those individuals working on behalf of FFC, not the member firms.
1.1 Our business
FootfallCam (FFC) is a privately held company and leading global provider of people counting solutions. We have a team of highly skilled engineers, manufacturing both hardware and software fully in-house in our U.K Headquarter, and applying their expertise in chosen fields to solve business challenges over the years. With a global network of reseller partners and continuous effort in research and development, we have relentlessly served organizations all over the world in sectors varying from retail, fast food restaurants, and museums to smart buildings and airports, for more than a decade.
1.2 Our Policies
FFC has established a zero-tolerance position on violations to the UK's anti-human trafficking and anti-modern slavery laws. We make sure our suppliers are aware of our policies and adhere to the same standards. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation.
The CLEARR values of Collaboration, Leadership, Excellence, Agility, Respect, and Responsibility, are the pillars of our culture. They embody everything that we do at FFC and how we do business. They outline the expectation of our people's behavior with colleagues, member firms, vendors and people around the world.
We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values which relating to human rights and modern slavery prohibiting child and forced labor and promoting humane treatment. These principles are to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
Child Labor Principle:
We will not tolerate the use of child or forced labor and not accept child labor in any stage of manufacturing or any practice that inhibits the development of children.
Forced Labor Principle:
We do not use, support or benefit from any form of forced labor. Huber prohibits physical abuse of employees and the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor or slave labor.
Humane Treatment Principle:
We treat every human being with respect as a base line expectation for human rights.
Human Trafficking Principle:
We denounce any act involved in the recruitment, abduction, transport, harboring, transfer, sale or receipt of persons within national or across international borders, through force, coercion, fraud or deception. Huber expects all employees to be vigilant and report any acts of slavery and human trafficking discovered during their employment.
1.3 Due diligence processes
We undertake due diligence in relation to slavery and human trafficking when considering taking on new suppliers, and review our existing suppliers on a periodic basis. Our due diligence and reviews include:
- Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
- Evaluating the modern slavery and human trafficking risks of each new supplier
- Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified
- When a supplier is deemed to be higher risk by country of origin and/or lack of suitable policy/processes, an investigation is raised and assessed by senior members of the purchasing team which can result in the vendor being inactivated.
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
1.4 Training
FFC requires all employees within the organization to complete training on modern slavery. The organization's modern slavery training covers:
Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labor engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the organization;
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and "Stronger together" initiative;
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps the organization should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organization's supply chains.
1.5 Awareness-Raising Program
The organization has raised awareness of modern slavery issues by circulating information to employees.
The information explained to relevant employees:
- The principles of the Modern Slavery Act 2015 and how it applies to FFC;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organization; and
- What external help is available, for example through the Modern Slavery Helpline.
We are currently improving our colleague mandatory training and planning to strengthen knowledge through these activities.